ANTI- MONEY LAUNDERING (AML) GUIDELINES AND KNOW
YOUR CUSTOMER (KYC) PROCEDURES
Money Laundering
is a type of financial crime that poses greater risk and challenges
to the financial sector. It can be called a process by which money
or other assets obtained as proceeds of crime are exchanged for
“clean money” or other assets with no obvious link to their criminal
origins. It
involves the processing of criminal proceeds in order to
disguise their illegal origin.
Money Laundering often requires the usage of the products and
the delivery channels offered by the financial sector and disrupt the
financial
stability, as it can lead to severe disturbances in the normal
social life. Increasing instances of money laundering and the growing
vulnerability of
the financial sector in the process makes it imperative for the
players in the financial markets, such as banks and money exchange
companies, to guard
themselves against the menace of money laundering.
Internationally, it is increasingly being recognized that money exchange
sector is also susceptible
to the money laundering schemes like other sectors such as
banks, mutual funds etc. This is because of the fact that the money
exchange products also
offer the stored value similar to the banking products in
certain cases.
Money Laundering is the process of concealing financial
transactions to make illegitimate money, derived from illegal activities
such as embezzlement/
corruption/ illegal gambling/ terrorism/ organized crime, appear
legitimate. Its main objective is to hide the true source of illegal
proceeds and make
them legally usable, by converting them into legitimate money
through a series of financial transactions. Technological advancements
have helped money
launderers adopt innovative means to transfer funds faster
across continents making detection and preventive action more difficult.
The attempted
misuse of the financial system for perpetration of frauds has
been recognized globally as a major problem that needs to be
continuously tackled at
every level in a dynamic manner.
Anti-Money Laundering (AML) is a term mainly used in the
financial and legal industries to describe the legal controls that
require financial
institutions and other regulated entities to prevent or report
money laundering activities.
Today, all financial institutions globally are required to
monitor, investigate and report transactions of a suspicious nature to
the financial
intelligence unit of the Central Bank in the respective country.
For example, a financial institution must perform due diligence by
having proof of a
customer’s identity and that the use, source and destination of
funds do not involve money laundering.
Managing money laundering requires the coordinated approach
among the financial services, regulatory authorities and the law
enforcement agencies all
supported by an appropriate statutory framework. The financial
institutions as the players in the industry are impacted by the money
launderer’s
operations and require a systematic framework to counter these
vulnerabilities.
Ahalia Money Exchange & Financial Services Private Limited
in accordance with the circulars and
regulations issued by the Reserve Bank of India and applicable
international standards in this
regard has put in place systems and procedures to combat money
laundering and identification of suspicious activities. The objective of
the same is to
ensure that transactions routed through the company never become
a cause for disguised criminal activities or are the routes of
organized crime.
INTRODUCTION
Financial sector in the 21st century, including money
exchange companies, faces serious threats of the white-collar crimes
that are
happening within the sector. These crimes are unlike the
traditional crimes and often take place intelligently without leaving
any trial for tracing
the crime. Financial crime cost a lot to the financial
institutions in particular and to the society at large.
Internationally, money laundering has been considered as a
threat to the national security and economic activity as it is often
associated with the
financing of terrorism and also evasion of taxes. This increases
the attention of the regulatory and statutory authorities to prescribe
guidelines/rules to ensure that the financial sector does not
contribute to the money laundering process either intentionally or
unintentionally.
Compliance with this statutory/regulatory provision is,
therefore, a key challenge to the financial sector in the present
scenario.
Compliance with the statutory/regulatory provisions requires
clear understanding of the regulations in the true spirit and the nature
and depth of the
menace that the regulations are trying to curb. It is therefore
necessary that the players in financial markets should understand the
concept of money
laundering in general and try to analyze the framework that
needs to be adopted within the entity to ensure that the products and
channels offered by
them do not become vehicles to the money launderers.
OUR GOAL
As a proactive and responsive company, Ahalia Money Exchange and Financial Services Pvt. Ltd. consider it our moral,
social and economic responsibility to prevent
the misuse of the financial system for laundering proceeds of criminal
activities and to
coordinate the global war against money laundering. Our role in
curbing this global reality begins with stringent Know Your Customer
procedures.
Imbibing the true spirit behind the international financial
community’s resolve to fight money laundering, Ahalia Money Exchange and
Financial Services Private Ltd. has resolved to conduct day - to
- day business with due skill, care and diligence and seek to always
comply with both
the letter and spirit of relevant laws, rules, regulation, codes
and standards of good practices. In the light of the guidelines
received from Reserve
Bank of India and based on earlier experiences by the financial
community, a standardized and uniform policy framework has been adopted
to ensure
appropriate customer identification and monitoring of unusual/
suspicious transactions on an ongoing basis. We prohibit all payments of
remittances to
charitable and religious organizations and trade related
remittances.
With more emphasis as disclosed in the preface to Anti-money
Laundering and combating terrorism activities, Ahalia Money Exchange
& Financial
Services Private Limited strives its best efforts in designing
and implementing the internal policies and continuous staff training so
that the
movement of funds through this organization does not culminate
in financing the harmful activities which impose severe threat to the
humanity as a
whole.
We look into a transparent business environment in which both
the service to the customer and compliance with the regulations on high
esteem as well as
extending all supports by way of compliance on regulations
issued by RBI.
The directives issued by the RBI is updated and implemented
throughout the entire team of the organization and periodical checks are
made as to whether
the same is being adhered to or not. Being committed to the
highest level of transparency in transactions, we have developed systems
and procedures to
monitor all the transactions for any suspected money laundering
activities.
The manual describes an outlook into the policies and procedures
designed by us, keeping in mind the regulations and how the system
works in order to
curb the activities associated with Anti-money laundering
activities, prevention of organized crimes etc.
The manual gives in detail the entire policies and procedures
followed by the company as regards the Anti-money laundering compliance,
broadly
classified under the major heads like Know Your Customer,
handling transactions, documentation, monitoring and control, reporting
suspicious
transactions, Legal position and obligation and guidelines to
identify suspicious transactions.
Know Your Customer Policy – Key elements
The objective of this policy is to prevent the Company (AMEFS)
from being used, internationally or unintentionally, by criminal
elements for money
laundering activities. This policy also enables Ahalia Money
Exchange & Financial Services Private Limited to know/understand
their customers and
their financial dealings better which in turn help them to
manage their risk prudently.
The policy shall consist of four key elements
A.
CUSTOMER ACCEPTANCE POLICY (CAP):
*
No transaction is conducted in anonymous or fictitious/binami
names and also to ensure that the identity of the person does not match
with any person
with known criminal background or with banned entities such as
individual terrorists or terrorist organizations etc.
*
Documentation requirements and other information to be collected
in respect of different categories of customers depending on perceived
risk and
keeping in mind the requirements of Prevention of Money Laundering Act, (PMLA), 2002,as amended by Prevention of Money Laundering (Amendment) Act, 2009 and guidelines issued by Reserve Bank of India.
*
Not to undertake any transaction unless the customer submits the identity or document as per the classification.
*
To have built in safeguards to avoid customer harassment and not too restrictive denying services to general public
*
The customer profile shall be a confidential document and details
contained therein shall not be divulged for cross selling or any other
purpose.
B.
CUSTOMER IDENTIFICATION PROCEDURE (CIP):
The Customer Identification means identifying the customer and
verifying the customer his/her identity by using reliable, documents,
data or
information. Ahalia Money Exchange & Financial Services
Private Limited needs to obtain information necessary to establish, the
identity of new
customers.
The detail of information required from customers is mentioned below:
Transaction with individuals
*
Legal name and any other names used
*
Correct Permanent address
Documents to be required for Identification
Passport (ii) PAN Card (iii)
Voter’s Identity Card (iv)
Driving License (v) Aadhar Card (vi) Identity Card issued by the
employers or other authority (vii) Letter from a recognized public
authority or public
servant verifying the identity and residence of the customer
Telephone bill (ii) Bank account statement (iii) Letter from any
recognized public authority (iv) Electricity Bill (v) Ration Card (vi)
Letter from
employer (vii) Passport (viii) Voters Identity Card (ix) Driving
License
Establishment of business relationship - Corporates.
*
Name of the Company
*
Principal place of business
*
Mailing address of the Company
*
Telephone/Fax Number
Documents to be required for Identification.
Certificate of incorporation and Memorandum & Articles of
Association (ii) Resolution of the Board of Directors to deposit the
money in the Company
along with list of authorized signatories (iii) Power of
Attorney granted to its Managers, Officers of employees to transact
business of its behalf
(iv) Copy of PAN allotment letter (v) Copy of the Telephone
Bill.
Establishment of business relationship -
Documents to be required for
Partnership firms
Identification
*
Legal Name
*
Address
*
Names of all Partners and their address
*
Telephone numbers of the firm and Partners
(i) Registration Certificate, if registered
(ii) Partnership deed (iii) Power of Attorney granted to a
Partner or an employee of the firm to transact business on its behalf
(iv) Any officially
valid documents, identifying the Partners and the persons
holding the Power of Attorney and their addresses
(v) Telephone bill in the name of firm/partner.
Establishment of business relationship
- Documents to be required for
Trusts & Foundations
Identification
*
Names of Trustees, Settlers, beneficiaries and signatories
*
Names and address of the Founder, the Managers/Directors and the Beneficiaries
*
Telephone/Fax Number
(i) Certificate of registration, if registered (ii) Power of
Attorney granted to transact business on its behalf (iii) Any officially
valid document to
identify the Trustees, Settlers, beneficiaries and those holding
Power of Attorney, Founders/ Managers/ Directors and their address (iv)
Resolution of
the managing body of the foundation/ association (v) Telephone
bill.
C.
MONITORING OF TRANSACTIONS:
*
Regular monitoring of policy and its implementation.
*
Effective controls shall be implemented.
*
Transactions in the accounts will also be monitored with a view
to timely submitting to FIU-IND by the Principal Officer , the Cash
Transaction Report
(CTR) in respect of cash transactions of Rs. 50,000/- (Rupees
Fifty thousand only) and above undertaken in an account either singly or
in an integrally
connected manner.
*
Transactions of suspicious nature and/or any other type of
transaction notified under PMLA will be reported by the Principal
Officer to Financial
Intelligence Unit – India in Suspicious Transaction Report (STR)
format.
*
A record of CTR & STR transactions will be preserved and maintained for the period as prescribed in PMLA.
*
The company may ask sources of funds before accepting deposits
from customers requiring higher due diligence as briefed hereunder:
*
i. Non-resident customers.
ii. Trusts, Charities, NGOs and Organizations receiving donations.
iii. Companies having close family shareholding or beneficial ownership.
iv. Politically exposed persons (PEPs) of foreign origin and
v. Those with dubious reputation as per public information available etc.
D. RISK CATEGORISATION
For the purpose of Risk Categorization, individuals (other than
High Net Worth) and entities whose identities and source of income can
be easily
identified and transactions by whom by and large conform to the
known profile may be categorized as low risk.
Custom that are likely to pose a higher than average risk should
be categorized as medium of high risk depending on customers
background, nature and
location of activity, country of origin, source of funds and his
client profile etc.
Company will apply enhanced due diligence measures based on the
risk assessment, thereby requiring intensive ‘due diligence’ for higher
risk customers,
especially those for whom the sources of funds are not clear.
Examples of customers requiring enhanced due diligence include
non-resident customers,
customers from countries that do not or insufficiently apply the
FTAF standards, high netwoth individuals (HNIs), trusts charities, NGOs
and
organizations receiving donations, politically exposed persons
(PEPs), non-face to face customers and those with dubious reputation as
per public
information available etc.
It is important to bear in mind that the adoption of customer
acceptance policy and its implementation should not become too
restrictive and must not
result in denial of services to general public.
Guidelines for Money Transfer Service Schemes.
A.
Identification of the Customer
*
Before effecting a transaction, the staff should confirm the
identity of the customer with the help of any valid photo identity card
/document that
helps in such identification.
*
The customer should produce the above documents in original and staff member has to ensure its genuineness.
*
Inspection of all documents should be carefully done. The photo,
name, signature, expiry date, etc. given in all the documents and
papers should be
carefully checked.
*
Every time the staff should ask for the original identity of the
customer and counter check the same with the information available in
the customer
database.
*
The customer, the concerned staff and the cashier are required
to sign the application to execute any transaction. "No Signature No
Transaction" shall
be the thumb rule.
B. Registering the Customer
*
Valid identification of customers to avail Money Transfer payments is mandatory.
*
Customer database to be maintained by all branches and scanned
copies of the identification documents kept on record. For regular
customers, we propose
to put in place a system for registering the customers with a
Customer Reference Card having a Unique Number.
*
The History of the transactions done by any customer could also be
accessed at any point of time for scrutiny under the proposed
dispensation.
C. Transaction Form Filling
*
Individual customer shall fill in the required forms prescribed by the service providers.
*
Copy of a valid ID is compulsorily taken to avail the service.
*
Modifications or Additions in the Receive Now form shall be done
at the respective branches by a specially designated person following
prudent
procedures.
*
The forms shall be signed by the customer in the presence of the designated officer only.
*
Maintain and preserve the records of necessary forms and
Beneficiary photo id proof at the branch locations for a minimum period
of 10 years from the
date of transaction.
-
High Value Transactions
*
Customer, whether registered or not, have to declare details
such as purpose of remittance and give the details of the sender.
*
Maximum amount allowed under a single transfer is USD 2500/- as per extant guidelines of Reserve Bank of India.
*
The maximum number of transactions an individual can receive in a calendar year is now fixed at thirty.
*
The purpose of remittance has to be for domestic use/family
maintenance. Remittances for other purposes like trade or commercial,
charitable trust,
donation etc. are not allowed.
*
The branches shall ensure to take a declaration from the
beneficiaries confirming the above purpose and number of transaction.
*
The maximum amount a beneficiary can collect in cash in a day is
Rs. 50,000/-. More than one transaction shall not be paid to a single
beneficiary in
cash in a day. Any payment above Rs. 50,000/- shall be affected
by A/C payee cheque for the amount.
*
Points of doubts, if any should be immediately referred to the
Principal Officer at Corporate Office before effecting payments.
*
The entire edifice is erected on transparency of our financial
and regulatory reporting with swift disclosures of any breaches.
Guidelines for Money Changing
Reserve Bank of India has brought about detailed Anti-Money
Laundering (AML) guidelines to enable AMCs to put in place proper policy
framework and
systems and procedures for prevention of money laundering while
undertaking money changing transactions.
In the light of the increased concern regarding money laundering
activities and to prevent the company being misused by such activities,
Ahalia Money
Exchange & Financial Services Private Limited has formulated
suitable policies and procedures in this regard. The policy framework
known as ‘ Anti-Money Laundering Guidelines and
Know Your Customer Procedure’
has been put in place with due approval from the appropriate authority.
A. Money Laundering
Money laundering is a process by which money or other assets
obtained as proceeds of crime are exchanged for ‘clean money’ or other
assets with no
obvious link to their criminal origins.
The offence of money laundering has been defined in Section 3 of the Prevention of
Money Laundering Act, 2002 (PMLA) as “whosoever directly or indirectly attempts to
indulge or knowingly assists or knowingly is a party or
is actually involved in any process or activity connected with the
proceeds of crime
and projecting it as untainted property shall be guilty
of offence of money laundering”.
B. Anti Money Laundering Measures.
The purpose of prescribing Anti-money laundering guidelines is
to prevent the system of Authorized Money Changers engaged in the
purchase and sale of
foreign currency notes/travelers’ cheques from being used for
money laundering. Therefore, Anti-money laundering measures would
include:
a) Identification of customers according to ‘Know Your Customer’ norms
b) Recognition, handling and disclosure of suspicious transactions.
c) Appointment of Principal Officer
d) Staff Training
e) Maintenance of records
f) Audit Transactions.
C. Know Your Customer (KYC) Identification of customers
All transactions should be undertaken only after proper
identification of the customer. Photocopies of proof of identification
should invariably be
retained by the AMC after verifying the document in original.
Full details of name and address as well as the details of the identity
document provided
should also be kept on record. If a transaction is being
undertaken on behalf of another person, identification evidence of all
the persons concerned
should be obtained and kept on record.
D. Purchase & Sale of Foreign Currency notes & Travellers Cheques
*
For purchase of foreign exchange less than Rs. 50,000 or its
equivalent, photocopies of the identification document need not be kept
on record.
However,full details of the identification document and contact
details should be maintained in the encashment certificate.
*
For encashment in excess of Rs. 50,000 or its equivalent, the
photocopies of the identification document should be maintained for a
minimum period of
ten years.
*
Payment in cash in Indian Rupees to resident customers towards purchase of foreign currency notes and/or Traveller's Cheques from them may be
acceded to the extent of only US $1000 its equivalent per transaction .
*
Payment in cash in Indian Rupees to foreign visitors/Non-Resident Indian may be acceded to the extent of only US $3000 or its equivalent.
or
*
Currency Declaration Form has to be obtained where the amount of
forex tendered for encashment by a non-resident person returning
from abroad exceeds US $5000
*
All encashment within 30 days may be treated as single
transaction for the purpose. In all other cases AMCs should make payment
by way of “Account
Payee” cheque/demand draft only.
*
Sale of foreign exchange should be made only on personal
application and identification. For identification purpose, the passport
of the customer
should be insisted upon. Payment in excess of Rs. 50,000/-
towards sale of foreign exchange should be received only by account
payee cheque/demand
draft.
E. Establishment of Business Relationship
*
Relationship with a business entity like a company/firm should
be established only after obtaining and verifying suitable documents in
support of name,
address and business activity such as Certificate of
Incorporation under the Companies Act, 1956, MOA and AOA, Registration
Certificate of a firm (if
registered), Partnership deed, etc.
*
A list of employees who would be authorized to transact on
behalf of the company/firm and documents of their identification
together with their
signatures, should also be called for. Copies of all documents
called for verification should be kept on record.
F. Recognition and reporting of suspicious transactions
Staff should be always vigilant against money laundering
transactions at all times. A transaction may be of a suspicious nature
irrespective of the
amount involved. Some possible suspicious activity indicators
are given below:
*
Customer is reluctant to provide details/documents on frivolous grounds.
*
The transaction is undertaken by one or more intermediaries to
protect the identity of the beneficiary or hide their involvement.
*
Large cash transactions
*
Size and frequency of transactions is high considering the normal business of the customer
*
Change in the pattern of business transacted.
G. Appointment of Principal Officer
Our Company has appointed Manager-FFMC to be designated as the
Principal Officer posted at Corporate Office of the Ahalia Money
Exchange &
Financial Services at the below mentioned address.
SSS Plaza, 1st Floor,
Palakkad Road,
Kizhakkumapattukara,
East Fort,
Thrissur – 680 005.
Ph: 0487-2434900 - 08
H. Responsibility of Principal Officer
*
Monitoring and reporting of transaction and sharing of information as required by the Competent Authority.
*
Implementation of ‘Know your Customer’ (KYC) Policy-Anti Money Laundering Standards
*
Training of staff and preparing detailed guidelines/handbook for detection of suspicious transactions
*
Preparing annual reports on the adequacy or otherwise of systems
and procedures in place to prevent money laundering and submit it to
the Top
Management within 3 months of the end of the financial year
*
Submission of Cash Transaction Report(CTR) and Suspicious Transaction Report-(STR) to the FIU-IND.
I.
Reporting of Suspicious Transactions
It is the duty of all staff/Officers to report suspicious and
unusual transactions to the Principal Officer at Corporate Office. All
suspicious
transactions should be reported to the Principal Officer before
they are undertaken. Full details of all suspicious transactions,
whether put through
or not, should be reported, in writing, to the Principal
Officer. Any transaction which seems suspicious may be undertaken only
with prior approval of
Principal Officer. If the Principal Officer is reasonably
satisfied that the suspicious transaction has or may have resulted in
money laundering,
Principal Officer should make a report to the FIU-IND at the
following address:
The Director FIU-IND
Financial Intelligence Unit – India
6th Floor, Hotel Samrat,
Chanakyapuri
New Delhi - 110 021
J.
Training of Staff
All the Managers and Staff would be trained to be aware of the
policies and procedures relating to prevention of money laundering,
provisions of the
PMLA and the need to monitor all transactions to ensure that no
suspicious activity is being undertaken under the guise of money
changing.
The Company will have an ongoing training programme for consistent implementation of the AML measures.
K. Maintenance of Records
The following documents should be preserved for a minimum period of ten years from the date of transactions.
*
Maintain and preserve the records of necessary forms and
Beneficiary photo id proof at the branch locations for a minimum period
of 10 years from the
date of transaction.
*
Copy of the monthly Cash Transaction Report (CTR) submitted to the FIU-IND
*
Statements/Registers prescribed by the Reserve Bank from time to time.
*
All Inspection/Audit/Concurrent Audit Reports.
*
Annual Reports of the Principal Officer submitted to the Top
Management on the adequacy or otherwise of systems and procedures in
place to prevent
money laundering.
*
Details of all suspicious transactions reported in writing or otherwise to the Principal Officer.
*
Details of all transactions involving purchase of foreign
exchange against payment in cash exceeding Indian Rs. 10,00,000 from
interrelated persons
during one month.
*
All correspondence/reports with the appropriate authority in connection with suspicious transactions.
*
References from Law Enforcement Authorities, including FIU,
should be preserved until the cases are adjudicated and closed.
-
Transaction Audit
The Concurrent Auditor/Inspecting officials should check all
transactions to verify that they have been done in compliance with the
anti-money
laundering guidelines and have been reported as required.
Compliance on the lapses, if any, recorded by the concurrent auditor
should be put up to the
Board. A Certificate from the Statutory Auditor on the
compliance with AML guidelines should be obtained at the time of
preparation of the Annual
Report and kept on record.
General Guidelines
-
Registration
All money changing transactions shall be carried out with due
diligence as prescribed by the RBI and other laws in force. In the case
of other money
changers, the branches shall ensure that their licence is valid,
officials transacting business are authorized and all payments are made
only through
Crossed Account Payee cheques.
2. Monitoring and Control
All relevant reports of all Inward Remittance transactions and
Money Exchange transactions have to be generated at day end at all the
branches. Branch
Manager shall scrutinize this report on daily basis, duly sign
for having verified them and preserve this documentation for ten years
from date.
Branch Head is appointed at every branch. The Branch Head shall
be responsible for the execution and implementation of the Regulations
issued by the
Reserve Bank of India and our Anti Money Laundering policies
& Procedures. They shall also be responsible
for reporting any suspicious transactions directly to the
Reporting Officer. They shall take instructions from the Reporting
Officer and shall report
to him on all matters regarding compliance.
The Concurrent Auditor of the company shall in their monthly
audit report mention on the efficacy of the implementation of the
policy, procedures and
the extent control exercised.
3. Compliance
The Branch Heads or the Branch In-charge shall be deemed as the
Branch Compliance Officer and he/she shall ensure that in the day to day
operations,
all the compliance instructions shall be strictly adhered to.
Any deviation shall be brought to the attention of Corporate Office.
Wilful suppression
of material information from the Corporate Office will be
treated as major act of misconduct and appropriate action will fall to
be considered.
Our Company has appointed Head Audit to be designated as the
Chief Compliance Officer posted at Corporate Office. The branch
compliance officers shall
report to the Chief Compliance Officer on all matters relating
to compliance. The responsibility of the CCO will be as follows:-
a) Develop Anti-money laundering and compliance procedures and
programmes in accordance with the regulatory prescriptions.
b) Create and implement a plan for training the staff across the network.
c) Develop and maintain formal written procedures for reviewing transactions of suspicious activity.
d) Carry out regular, timely and thorough transaction reviews.
e) Review suspicious activity reports received from branches and carries out further analysis wherever necessary.
f) Review ad carry out investigations relating to reports received at Corporate Office from branches.
g) Establish and maintain close working relationship with appropriate regulatory bodies.
h) Identify trends and opportunities to further improve the
company’s anti- money laundering measures and its compliance.
i) Perform on-going compliance exercises including audit and mystery shopping.
-
Punishment for Money Laundering
*
RI for 3 to 7 years
*
RI for 10 years if crime is offence under Narcotic drugs etc
*
Fine up to Rs. 5 lacs
5. Verification of character and antecedents of new recruits
The HR Department will check the character and antecedents of all
new staff by checking their references. This will be done before issuing
the offer of
employment.
6. Customer Education
The Company recognizes the need to spread awareness on KYC, Anti
Money Laundering measures and the rationale behind them amongst the
customers and shall
take suitable steps for the purpose
7. Introduction of New technologies – Travel Currency Cards
The Company will pay special attention to the money laundering threats arising
from new
or developing technologies and take necessary
steps
to prevent its
misuse for
money laundering
activities and also will ensure
that appropriate KYC
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procedures are duly applied to the customers using new technology driven products.
8. Combating Financing of Terrorism
In terms of PML Rules, suspicious transaction should include inter
alia transactions which give to a reasonable ground of suspicion that it
may involve the
proceeds of an offence mentioned in the schedule of the PMLA
regardless of the value involved. Company have developed suitable
mechanism through
appropriate policy framework for enhanced monitoring of transactions
suspected of having terrorist links and making suitable reports to the
Finance
Intelligence unit – India (FIU-IND) on priority.
9. Risk Management
The Board of Directors of the company shall ensure that an effective
KYC programme is put in place by establishing appropriate procedures
and ensuring
effective implementation. It should cover proper management
oversight system and controls, segregation of duties, training and other
related matters.
Responsibility should be explicitly allocated within the Company for
ensuring that the policies and procedures of the Company are
implemented effectively.
The company will endeavour to pay special attention to any money
laundering threats that may arise from new or developing technologies
that might favour
anonymity and take measures to prevent their use of money laundering
purposes and financing of terrorism activities.
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